On May 31, 2016, the Commission filed a complaint against Momentum Investment Partners LLC (doing business as Avatar Investment Management) (“Avatar”) and Ronald J. Fernandes (collectively, the “Defendants”). The complaint alleged that, from May 2013 to March 2014, the Defendants violated federal securities laws by failing to disclose to some of Avatar’s advisory clients certain fees they were being charged. SeeComplaint.

The Defendants were ordered to pay a total of $233,676.37in disgorgement, prejudgment interest, and penalties. The Commission was ordered to hold all funds, together with interest and income earned thereon (collectively, the “Fund”), pending further order of the Court. See the Defendants’ Final Judgments.